Kevin GilheanyKevin Gilheany is a marine consultant and owner of Maritime Compliance International in New Orleans. He works with companies to help increase profitability through improved compliance and management systems. Gilheany is a retired U.S. Coast Guard marine inspector, certified marine surveyor and auditor, and crew endurance management expert. He has also provided contract training to the U.S. Coast Guard, was an adjunct instructor of maritime security at Tulane University’s Homeland Security Studies Program, and has contributed to marine industry publications. He can be reached at kgilheany@marcomint.com or www.maritimecomplianceinternational.com.

If you operate a commercial vessel 79 feet and greater that operates in U.S. waters, you only have three weeks left to submit your first EPA VGP annual report.
Under the first Environmental Protection Agency (EPA) Vessel General Permit (VGP) an annual report was only required to report non-compliance. Under the current 2013 VGP, an annual report is required to be submitted for all vessels covered by the permit, which includes all commercial vessels 79 feet and greater, operating in U.S....

The moratorium for requiring permits for incidental discharges from commercial vessels less than 79 feet is set to expire on Dec. 18.Currently, the
Environmental Protection Agency does not require Clean Water Act permits for
incidental discharges (other than ballast water) from commercial vessels less
than 79 feet. However, this moratorium is set to expire on Dec. 18.
According to
EPA sources, it is unknown whether the moratorium will be extended past Dec.
18. If another moratorium is...

In anticipation of the possibility that Subchapter M will become final in 2015, I will be presenting a talk entitled "Subchapter M - Top 10 Things You Need to Know" at the Pacific Marine Expo in Seattle on Nov. 19.Don’t let your guard down. I have noticed many in the towboat industry are suffering from Subchapter M fatigue. Understandably, many are sick of the constant hype and have become desensitized at best, and disgusted at worst, at the mere mention of Subchapter M.
I have...

The towing vessel inspection final rule has been put off until March, but the new delay buys time for companies to prepare.The expected release date for the Subchapter M towing vessel inspection regulations Final Rule is now March 2015. While some may find the moving goalpost frustrating, the delay buys time for preparation.
Anyone who may be affected by this regulation should read over the Notice of Proposed Rulemaking (NPRM). It is worthwhile to consider what equipment and other changes...

The Coast Guard has posted September 2014 on its regulatory agenda for the release of the towing vessel inspection final rule.The Coast Guard has posted September 2014 on its regulatory agenda for the release of the towing vessel inspection final rule.
While many
are already aware of the date, it is interesting to note that Subchapter M is
expected to be released as a final rule. There has been speculation that due to
the large volume of comments, Subchapter M may be changed...

Get your best captains involved in developing your company's safety management system.Writing down
the best procedure for a particular operation in a safety management system (SMS)
helps standardize operations and minimize human error.The content
of each SMS will vary greatly, even within the same industry. That’s because it’s
up to the company using or developing it to determine which operations should
be included. Some regulatory requirements or industry programs dictate what
topics...

Hopefully you made the Jan. 30 deadline to submit your Nontank Vessel Response Plan to the Coast Guard.Hopefully you
made the Jan. 30 deadline to submit your Nontank Vessel Response Plan (NTVRP)
to the Coast Guard.
On Jan. 31,
all old nontank vessel response plans were to be deactivated, the Coast Guard
said. That’s because the long awaited final rule for the nontank vessel
response plan regulations were finally published Sept. 30, 2013. The old nontank
vessel response plans were...

The 2008 Environmental Protection Agency (EPA) Vessel General Permit (2013 VGP) expires on Dec. 19 and the new EPA VGP 2013 goes into effect the same day.The 2008 Environmental Protection Agency (EPA) Vessel General Permit (2013 VGP) expires on Dec. 19 and the new EPA VGP 2013 goes into effect the same day. The following is a summary of most of the issues vessel operators might be concerned with.
The new 2013 VGP applies to non-recreational vessels 79 feet or greater, just as the 2008...

What you should know about the training and certification of facility security officers (FSOs).Some of my
clients have asked about the training and certification of facility security
officers (FSOs).
Ten years ago
the MTSA regulations were published. The Coast Guard listed FSO requirements that
said the officers must have “general knowledge, through training or on the job
experience in the following,” and then listed the topics. It also said that FSOs
must also “have knowledge and...

Maritime security regulations call for a Declaration of Security (DOS) to be used during certain times when there is a heightened security threat.Maritime
security regulations call for a Declaration of Security (DOS) to be used during
certain times when there is a heightened security threat.
The
International Ship and Port Security (ISPS) Code takes a more general approach
to the DOS than the U.S. Coast Guard. Coast Guard regulations spell out which
types of interfaces require a DOS...